April 30, 2013
UNITED STATES OF AMERICA, Plaintiff,
KIRK SANDERSON, et al., Defendant.
CLEMENTE M. JIM§NEZ, ESQ., California State Bar Number 207136 Sacramento, CA, Attorney for Kirk Sanderson.
JARED DOLAN, Attorney for Plaintiff.
DEFENDANT KIRK SANDERSON'S REQUEST FOR EXTENSION OF TIME TO SUBMIT SECURED BOND DOCUMENTATION TO THE COURT
CAROLYN K. DELANEY, Magistrate Judge
IT IS HEREBY STIPULATED by and between Assistant United States Attorney Jared Dolan, Counsel for Plaintiff, and Attorney Clemente M. Jimenez, Counsel for Defendant KIRK SANDERSON, that the deadline for the Defendant to submit secured bond paperwork to the Court be extended to May 10, 2013.
On April 15, 2013, the parties appeared before Judge Brennan to address Defendant KIRK SANDERSON'S custody status. The court ordered Mr. Sanderson released on a $100, 000 bond to be secured by a $50, 000 bond posted against the Defendant's mother's and step-father's property in Vacaville, California, and the remaining $50, 000.00 to be secured by a bond to be posted against any equity in the home of the Defendant's father and step-mother. Mr. Sanderson was given until the close of business on April 22, 2013, to submit the appropriate paperwork to the court. This court, thereafter, accepted the proposed stipulation of the parties extending the May 22nd deadline to May 29th.
Although Mr. Sanderson and his family have made significant headway in securing appraisals and gathering the necessary title documentation, they have been unable to complete the process, and will need the additional time requested to do so.
The Kirks have completed the appraisal on their home, and are now in the process of gathering title paperwork. The Jacksons are also in the process of gathering the necessary documentation.
In communicating with the parties, it is believed that gathering of documentation and recordings of title documents can be completed by Friday, May 10, 2013.
For the aforementioned reasons, the parties respectfully request the Court grant the requested extension of time for the Defendant to submit his secured bond paperwork to the Court.
IT IS SO ORDERED, that the request for extension of time for the Defendant to submit secured bond paperwork to the court be granted. The defendant shall submit all necessary paperwork to the Court by close of business on May 10, 2013.